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Publication Date
10/26/2022
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Publication Date
11/18/2022
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Publication Date
11/22/2022
On October 19, 2022, USCIS published major revisions to their Policy Manual on the English and/or Civics disability waiver for naturalization applicants. Overall, these changes were a welcome improvement in access to the disability waiver. However, we opposed the sections in the revised Policy Manual and N-648 that add a question about understanding the oath of allegiance. The oath waiver and the English/civics disability waiver derive from separate sections of the law and have different eligibility standards.
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Publication Date
11/22/2022
On October 19, 2022, USCIS published major revisions to their Policy Manual on the English and/or Civics disability waiver for naturalization applicants. Overall, these changes were a welcome improvement in access to the disability waiver. However, we opposed the sections in the revised Policy Manual and N-648 that add a question about understanding the oath of allegiance.
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Publication Date
01/23/2023
On December 19, 2022, USCIS published updates to its Policy Manual on how adjudicators should assess applications under the Public Charge ground of inadmissibility. This guidance accompanies the new final rule on Public Charge which took effect on December 23, 2023. The guidance is mostly positive, solidifying and strengthening longstanding public charge policy. However, the ILRC provided suggestions to clarify implementation of the new rule and help USCIS achieve their goals of ensuring that the public charge ground of inadmissibility is applied clearly, consistently, and fairly.
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On February 2, 2023, USCIS announced changes to the Policy Manual guidance on the one-year physical presence requirement for asylee/refugee adjustment. In a comment letter on February 16, 2023, ILRC commended USCIS on the changes. We believe they will increase fair and consistent adjudications for asylees and refugees seeking adjustment.
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Publication Date
03/08/2023
On March 8, ILRC provided comments on the USCIS proposed fee rule. In the comment, ILRC commended agency actions codifying fee exemptions. Additionally, ILRC requested that USCIS codify fee waiver eligibility standards and raise the income threshold for fee waivers. We also requested that fee increases be reduced for applications for lawful permanent residence, work authorization and family petitions, among others. Finally, the comment provides requested changes to various USCIS forms that are open for comment in conjunction with the proposed fee rule.
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Publication Date
03/08/2023
On March 8, ILRC responded to a request for input from the Office of Information and Regulatory Affairs (OIRA) on how to broaden public engagement with the public in the federal regulatory process. ILRC suggested that OIRA partner with community organizations to ensure that information is shared in the most effective way possible, including written materials and trainings. ILRC also made several process suggestions that OIRA can implement to reduce barriers to public participation.
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Publication Date
03/22/2023
On March 22, 2023, the ILRC sent a letter to USCIS acknowledging the implementation of biometrics flexibilities for domestic benefits applicants who live in remote areas. The ILRC commended the agency on its provision of flexibilities to ensure that all domestic applicants could continue with their benefits applications regardless of physical location in the United States. The ILRC further urged USCIS to expand these flexibilities to applicants abroad and highlighted the negative effects that consulate closures abroad have had on U and T visa applicants attempting to complete their biometrics abroad.
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Publication Date
03/27/2023
On March 27, 2023, the ILRC submitted comments on the Biden Administration’s proposed rule that would impose a rebuttable presumption against eligibility for asylum for those who transited through a third country before arriving in the United States. The ILRC detailed concerns with how this rule will essentially ban a large number of asylum-seekers from relief and how the rule impermissibly restricts the due process rights of asylum-seekers at the U.S.-Mexico border.
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Publication Date
04/11/2023
Our ILRC Texas team continues to stand alongside Texans to oppose the harmful and unconstitutional Operation Lone Star (OLS). This sign-on letter, drafted by the ILRC and signed by nearly 80 local, state, and national organizations, urges Texas officials to say “no” to two harmful bills, HB 7 and HB 20. These bills would codify OLS, promote racial profiling, and fuel anti-immigrant rhetoric that threatens our communities. The ILRC and the nearly 80 organizations that signed this letter support Texans who are demanding protection from these dangerous bills and from Operation Lone Star.
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Publication Date
06/20/2023
On June 20, 2023, the ILRC submitted a comment to USCIS regarding the proposed changes to From N-400, Application for Naturalization. ILRC commended the agency for a number of positive changes that streamlined and shortened the form. ILRC also made several suggestions to USCIS to clarify and narrow the information required from applicants to ensure that only relevant information is collected on the form.
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Publication Date
06/16/2023
The Immigrant Legal Resource Center submitted this letter on June 16, 2023, to thank USCIS for the many changes that have already been made to the USCIS Policy Manual and to provide further recommendations for changes to the Policy Manual that USCIS can immediately implement to increase access to immigration benefits and reduce backlogs. The letter provides suggestions that include ongoing recommendations from prior letters and engagements as well as new ones.
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Publication Date
08/07/2023
On August 7, 2023, the ILRC provided a comment to a recent USCIS Policy Manual update seeking to clarify who is subject to the public charge ground of inadmissibility. In the comment, ILRC provided suggested language for both the Policy Manual and the Form I-485 that would help to further lessen confusion that practitioners and applicants are facing in this area. ILRC also recommended changes to the USCIS web site for Form I-485 to ensure that information is consistent and accurate for applicants.
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Publication Date
08/23/2023
On August 23, 2023, ILRC submitted a comment on the proposed form that Immigration and Customs Enforcement (ICE) will use to collect information from the public about suspected violations. ILRC opposes the use of this form as it allows for anonymous, un-vetted information to be the basis of investigations and has a high likelihood of being used by abusers, unscrupulous employers and landlords, and others to harass and target immigrant communities.
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Publication Date
08/30/2023
On August 1, 2023, USCIS published long-awaited Policy Manual guidance on the definition and process for determining statelessness. ILRC commented favorably on most of the guidance and made suggestions for some improvements.
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Publication Date
10/16/2023
The ILRC commented on USCIS policy guidance regarding Safe Address and Special Procedures for Persons Protected by 8 USC 1367. ILRC commends USCIS for this guidance and provides suggestions for further strengthening the guidance.
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Publication Date
10/26/2023
ILRC submitted this comment on the N-600 Certificate for Citizenship on October 26, 2023, with suggestions on how to make the form more accessible and consistent with current law and policy, thus increasing access to citizenship.
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Publication Date
11/07/2023
On November 7, 2023, the ILRC submitted this comment on USCIS’s proposed changes to Form I-485, Application to Register Permanent Residence or Adjust Status. The comment provides detailed suggestions for alterations to the proposed form as well as suggested language the agency should include. ILRC urged the agency to revise the form to reduce barriers to permanent residence for applicants and adjudicators and to focus on ensuring that the form is accessible for pro se applicants.
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Publication Date
11/07/2023
ILRC led a sign-on effort to provide comment to USCIS on the proposed changes to Form I-485, Application to Register Permanent Residence or Adjust Status. The comment, submitted November 7, 2023, received over 120 signatures and requested that the agency revise the form for efficiency and to remove barriers to eligible applicants.
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Publication Date
11/08/2023
This is ILRC’s comment on the proposed EOIR rule (the rescission of what we referred to as Trump’s “Death to Due Process Rule”). The Trump rule attempted to change case briefing schedules, case timelines, judges’ control over cases, etc. – all in ways that would make it even harder for folks in immigration court to obtain immigration relief. ILRC has engaged in substantial advocacy to get rid of this rule, including being a plaintiff in the case challenging this Trump rule
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Publication Date
06/15/2023
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Publication Date
11/28/2023
ILRC wrote to USCIS leadership on behalf of local programs representing naturalization applicants with disability waivers in LA County USCIS. Despite major changes to the USCIS Policy Manual and Form N-648 on October 22, 2022, this office of USCIS resists implementation of the new guidance and continues to be dismissive and hostile towards applicants with disability waivers.
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Publication Date
01/08/2024
ILRC submitted this comment on the many proposed changes to U Visa Forms I-918, I-918A, and I-918B. ILRC commended the agency for many changes, including shortening Forms I-918 and I-918A and removing many questions about rare grounds of inadmissibility. ILRC also provided suggestions for how the agency could further streamline Forms I-918 and I-918A, and raised concerns about the expansion of Form I-918B.
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Publication Date
01/17/2024
Texas-based organizations comprised of, representing, and serving individuals and communities directly impacted by border enforcement measures write to Texas Members of Congress to seek solidarity and to implore not to worsen the crisis by layering over sweeping new federal border and asylum restrictions. The organizational letter highlights how these changes would have disastrous consequences not only for migrants but for Texas communities, who are presently living under the oppressive and unconstitutional Operation Lone Star.
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Publication Date
02/20/2024
On Feb. 20, 2024, the ILRC sent a letter to DHS Secretary Alejandro Mayorkas and Attorney General Merrick Garland urging the release of regulations in 2024. The purpose of the letter is to encourage the Biden Administration to publish regulations regardless of the political concerns of the upcoming election year. The ILRC focused on the release of some proposed regulations that have been scheduled for publication, and also urged the administration to rescind and replace asylum regulations leftover from the previous administration, and also to refrain from publishing additional regulations that restrict asylum at the southern border.